OSHA Leading Indicators Stakeholder Meeting 7 Nov. 2019 (Part 1)

This was a great meeting. It was too short, but there was a large amount of information shared. As you may have guessed, I may have spoken a lot more than my fair share. I am passionate about Leading Indicators, because I like the idea of making scientifically valid improvements without the need for medical interventions, or worse.

As promised, every time someone brought up the need for standardization, mandatory criteria, strict definition and cross industry bench marking, I stood up, and did my best Red Foxx fake heart attack while screaming "I'm coming Lizbeth, they're killing safety and turning leading indicators into a missed opportunity."

I may have overplayed my hand, because they stopped calling EMS after the second one;)

In all seriousness, I believe that requiring the employer to develop their own leading indicators, measurements and solutions will generate and maintain ownership which in my opinion enhances engagement at all levels of the organization.

However, at the meeting another aspect of "strict definitions" and "specific requirements" was brought up "smaller employers that lack dedicated safety professionals should not be left out in the cold, just because they cannot afford the price of admission". The workers at these companies deserve all the same protections as the workers at larger companies.

So,... realistically there must be sufficient guidance to allow smaller employers to implement a viable, cost effective program, without incenting bad actors to shirk their responsibilities to worker safety.

There are many ways to accomplish this, but it brings up at least one ethical question. If OSHA provides free assistance to one employer based on whatever criteria we use, don't they have to provide that same assistance to any U.S. employer? Obviously, this is just a starting point for these issues. In a state like California, where Cal/OSHA offers a consulting wing to assist employers with compliance questions, would this put them in the position of developing, implementing and maintaining complete leading indicator programs?

Is this an opportunity for the Small Business Administration to step in and fill a gap? Does it than remove the ethical question?

Or, is this an opportunity for a safety minded non-profit to step in and lend a pro bono hand, while increasing workplace safety awareness for small business?

Is this an opportunity for some sort of Public/Private multi-agency hybrid that is a giant pain in the rear end for hundreds of people, but ultimately generates a fair and workable system that ultimately improves worker safety and acceptance of responsibility (everyone chants as they carry little Rudy off the field on their shoulders)?

Aside from the fact that faking a medical condition is morally wrong,... What do you think?